Objectives of the Group Compliance Program
Complying with the many different sets of regulations under which the Group operates worldwide requires discipline, determination, commitment and leadership. Valeo has therefore put in place a Compliance organization based on several committees and a Group Compliance Program, the purposes of which are to:
- define Valeo’s Compliance policies ;
- train and inform Valeo personnel about these policies as well as related regulations and risks ;
- sensitize Valeo Business Partners to both those risks and regulations and Valeo’s expectations on them ;
- set up mechanisms to detect, correct and prevent behavior that may result in violations of the laws or regulations governing Valeo operations;
- encourage Valeo’s stakeholders to report to management, in strict Compliance with local laws, incidents that they, in good faith, believe:
– are in violation of laws or of Valeo policies,
– could have an impact on Valeo or its personnel, image or reputation.
Initially, Valeo is focusing on fighting antitrust practices and corruption and on protecting assets and information.
The program is now expanding to Economic Sanctions and Export Control.
The Group’s Compliance Organization
The Compliance organization is based on several committees and the total commitment of Valeo’s management as well as the personnel’s mobilization.
- Audit & Risks Committee
The Audit and Risks Committee is responsible for ensuring the effectiveness of the risk management and internal control systems. As such, it regularly ensures that Valeo is maintaining a comprehensive program to comply with all laws and regulations governing its business activities, and is conducting its affairs in an ethical and responsible manner.
- The Operational Committee
The Operational Committee, chaired by Valeo’s Chief Executive Officer, defines the directions and priorities of the Compliance Program, allocates the necessary means and resources, and oversees and manages its implementation.
Operational Committee members are then responsible for conveying Compliance messages throughout the organization either directly r via their own leadership teams.
- The Ethics and Compliance Office
The Chief Ethics and Compliance Officer initiates, manages and coordinates the implementation of the Compliance Program as defined by the Operational Committee, of which he/she is a member
Reporting to the Chairman of the Board and CEO, Valeo’s Chief Ethics and Compliance Officer provides regular program advancement updates to the Audit & Risks Committee.
To ensure effective implementation of the program, the Chief Ethics and Compliance Officer works closely with the National Directors, the Business Group Presidents, the Purchasing Director and Industrial Director, the R&D, the HR and the Finance Directors, the General Counsels and the Internal Control Director. All contribute actively, both individually and via their teams, to the program’s implementation and effectiveness.
- The Compliance Champions
Impeccable Ethics & Compliance is the backbone of Valeo’s business integrity, and part of its DNA. Valeo Compliance Champions, a global, cross-functional team with 60 members from a variety of networks (Sales, R&D, Projects, Finance, HR, Legal, Purchasing, etc.) have accepted to help promote the Compliance program within their area of responsibility.
Compliance Champions are available to help their peers and colleagues understand the policies and tools applicable to their activities, as well as all Ethics and Compliance initiatives.
They mostly serve as the “go to” person in case of questions or doubts from a Business Group, function or project team member, and guide their peers and colleagues by sharing their knowledge and experience and by directing them to the right person or persons to provide additional information.
- The management team
Ultimately, managers, from all countries and businesses, have a key role to play in advocating the program among their teams and making it part of Valeo’s day-to-day operations, at a global level.
This mobilization of the entire leadership team is a natural result of Valeo’s culture of Ethics and of its commitment to doing business with integrity. National Directors and site managers have a particularly important role to play in implementing the compliance program locally.
- Employees at large
E&C roles and responsibilities are clearly allocated among the various managers; Employees need to show E&C transversal competences and meet general and/or specific annual objectives.
Employees are specifically responsible for knowing and understanding the compliance program and the policies, taking all training in due course, using the Compliance Management System according the relevant policies, asking for help as needed, and alerting in case of doubts.
Group Compliance Program
- Policies and Guidelines
Valeo has defined strict policies concerning its interactions with its business partners.
As stated in its Code of Ethics, Valeo complies with antitrust laws in force in the European Union and in each country in which the Group operates. Valeo strictly prohibits the exchange of sensitive business data and illegal arrangements with competitors.
Fighting corruption is also an integral part of Valeo’s policy. A detailed anti-corruption program has been drawn up, covering gifts, entertainment and hospitality offered to customers, suppliers and partners, from both private and public sector. The program also covers relationships with agents, purchasing procedures, M&A due diligences, logistics chain risks, etc.
- Resources and support for employees
In order to help Sales, Project and R&D teams in particular to identify inappropriate agreements or discussions involving competitors, and to be proactive in avoiding them, a number of resources have been developed. These include FAQs, Dos and Don’ts, and recommendations for specific Valeo businesses or processes, and are available to all employees. Similarly, an anti-corruption handbook along with FAQs, Dos and Don’ts and procedures for selecting partners and suppliers have also been developed to help people make the right decisions. A set of decision-making tools complete the resources available.
Our aim is to provide all employees with the tools required to be proactive and make the right decisions, and to encourage them to turn to the right people at the right time. We have therefore made these tools available to everyone on a user-friendly Ethics and Compliance portal.
Employees are also encouraged to consult their line manager, Compliance Champion and the Chief Ethics and Compliance Officer and/or the Legal team.
The Valeo Compliance Management System
Valeo has put in place a Compliance Management System, available on PC, tablet and smartphone which allows those who need to follow a mandatory procedure and obtain pre approval or those who need to approve or deny a request to do it, easily and timely.
The system offers other features allowing Valeo to keep track of communications and to evidence compliance with procedures.
Education awareness, training: the cornerstones of Ethics and Compliance
- Education awareness
Education is provided and awareness is developed in a variety of ways, including orientation and induction programs, newsletters, team meetings and training sessions. The Executive Management regularly reminds staff that Ethics and Compliance form one of Valeo’s core values.
Training is an essential element of Valeo’s policy.
As to Compliance, it is available in the form of both training sessions and e-learning programs.
Tailored antitrust and anti-corruption training sessions
Are held on sites in the local languages. These sessions are mandatory for managers.
E-learning has been developed in 13 languages. It is mandatory for all managers and those who take part in particular projects or operations, in line with Valeo’s policies. It is strongly recommended for all other staff, who are regularly encouraged to follow the program.
In addition, special modules have been integrated into Valeo’s Leadership Development programs as well as training geared to specific functions such as sales, supply chain and purchasing.
A Compliance training plan is defined every year. It is implemented and overseen very closely by the Group Training teams and the Compliance team. Failure to participate in mandatory Compliance training may result in disciplinary action.
- Business partners’ Commitment
Valeo expects from its Business partners that they share the same business ethics and integrity values. Suppliers, service providers, third party intermediaries must sign Valeo Business Partner Code of Conduct, (English version) and distribute it to its teams.
Business partners are also expected to comply with both the laws and regulations of the countries in which they operate and Valeo related policies and guidelines. It is one of their contractual obligations.
- Business partners’ awareness development
In order to develop their understanding and awareness of antitrust and anti-bribery key challenges in general and Valeo’s policies and expectations in that respect, Valeo has developed 2 awareness development modules available via elearning.
Those modules are highly recommended for all business partners and they are mandatory for some of them, among whom engineers, agents and intermediaries and their teams assigned to a Valeo project or mission. Modules are available in English, French, German, Chinese, Japanese and Spanish by clicking on the following link elearning Modules.
Finally and in support of the elearning, Valeo has developed Third party awareness development handbooks. They are available in 8 languages and the English version is accessible here: Awareness development Handbooks.
- Alerts: risk prevention
Prevention is crucial. Valeo employees are encouraged to alert their management about a known or suspected violation of applicable laws, regulations, ethical standards or Valeo policies as soon as they become aware of it.
They can chose to inform their Manager, the Chief Ethics and Compliance Officer or the Internal Audit Director.
They may also decide to use the Valeo alert line. Operated by a third party provider, it gives Valeo employees globally, the opportunity to report in their own terms and language actual or potential frauds, or non compliance they might be aware of.
Third parties are permitted to use the alert line or to report non compliance issues they may see or be faced with through the line of alert, their usual point of contact or the Chief Ethics and Compliance Officer.
Alerts may be oral or written, in any of languages spoken at Valeo. Except when prhibited by a law, they can even be anonymous, if the alerter deems it really necessary. A detailed whistle blowing procedure is available.
Alerts are treated seriously, objectively, confidentiality, in compliance with local laws and the specific Valeo alert confidentiality and management procedure.
No whistleblower who reports a Compliance issue in good faith will be sanctioned in any way for doing so. Retaliation against whistleblowers is not permitted.
An alert is a serious action. Alerts that are unfounded or are aimed at damaging the reputation of another employee will not be tolerated either.